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legitimate interests regarding permanent residence or even acquisition of Russian citizenship. Of
course, we must consider that this obligation will probably only be implemented by the Russian
authorities with regard to compatriots. It is obvious that the integration through naturalisation of
HIV-positive citizens may objectively become an additional public burden and place an excessive
demand on the publicly-funded health care system in Russia.
6.2.4 Citizenship Policy at the supranational level
Today, in the Post-Soviet Space we can identify three levels of integration among members of the
CIS: 1) the general CIS level - for all members of Commonwealth, 2) 'quadriga' ('chetverka') – the
four states community, which involves more integrated cooperation between Belarus, Kazakhstan,
Kyrgyzstan and Russia and 3) the highest level of cooperation, namely between the Union State of
Belarus and Russia.78
Commonwealth of Independent States (CIS)
Originally, the development of citizenship policy of the CIS member states was influenced
by the first Russian citizenship law of 1991.This Citizenship Law was one of the most liberal in the
world. The law did not establish any language or other special requirements regarding acquisition of
citizenship, on the contrary, it set forth a wide range of circumstances allowing citizenship to be
obtained.79 From this the CIS Inter-Parliamentary Assembly developed the Recommendations from
29 December 1992 ‘About principles of citizenship regulation’. The aim of this document was to
protect human rights in the CIS, to reduce the number of stateless persons, to facilitate contacts
between people, to establish and maintain friendship and good relations with all states of the CIS. 80
On the basis of these Recommendations international agreements regarding dual citizenship
with Tajikistan (1996) and Turkmenistan (1994) were signed and ratified. However, these treaties
were often violated. In April 2003, on the initiative of the Turkmenistan authorities, the agreement
on dual citizenship was declared void. The Turkmen authorities began to force people with dual
citizenship either to refuse Russian citizenship, or to leave Turkmenistan. Thus, a special provision
was included into the Turkmen Constitution forbidding dual citizenship (Ginsburgs 2004: 437).
Thus, in 1990s, the leaders of the CIS member states attempted to harmonize the legislation
on citizenship through the adoption of the model law on citizenship. However, the draft of model
law offered by the Russian Federation was considered by the CIS member states as an attempt to
intervene in their internal affairs and reflected the Russian states’ desire to put pressure upon these
newly independent sovereign states. In the following years, Russia distanced itself from the
principles of the proposed model legislation developed by the CIS Inter-Parliamentary Assembly.
The entrance into force of the Federal law on 31 May 2002 N 62-FZ ‘About Citizenship of the
Russian Federation’ can be considered as the beginning of a new citizenship policy in Russia. The
Russian authorities have adopted several restrictive measures and practically prohibited dual
citizenship.
78
A.A. Golovko. State and legal problem of integration in the framework of the Union of Belarus and Russia. Herald of
Inter-Parliamentary Assembly of the CIS. St.Petersburg. 1998. Page 85. [3)$)*;) P.P. F+):$#=' 1"/#%+&D11
%).8-&+./*#"")-(+&*)*)%) =#E&"19=& * A)79# 5#$&+8.1 1 ?)..11. H#./"1; V#,(&+$&=#"/.;)@ P..&=:$#1
AO3. A.-F#/#+:8+%. 1998. A.85.]
79
Shestakova E.V. The model legislation in the CIS countries. International public and private law", 2006, N 1.
[N#./&;)*& L.H. V)-#$6")# 9&;)")-&/#$6./*) * ./+&"&E AO3. V#,-8"&+)-")# (8:$1<")# 1 <&./")# (+&*)",
2006, N 1].
80
Inter-Parliamentary Assembly of the Member States of the CIS. Newsletter. 1993. N 2. Page 20-21.
[V#,(&+$&=#"/.;&2 &..&=:$#2 %).8-&+./* - 8<&./"1;)* AO3. J"4)+=&D1)""'@ :7$$#/#"6. 1993. N 2. A. 20 21].
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